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Case Study

Review and remediation of the entire client base regarding AML/KYC requirements and review of the AML/KYC processes.

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Summary

Avantage Reply was tasked by a leading Wealth and Fund Management Bank to review and remediate the existing customer base KYC information, specifically for AML/CTF requirements. This task was required on the one hand due to changing regulatory requirements, on the other hand, because of the effect caused by Brexit on the customer’s UK branch.

The customer’s existing KYC requirements were not in line with the regulatory requirements anymore. The team first participated in the review of the information documentation present in the clients’/entities files from Luxembourg AML/CTF policy and the collection of the missing or outdated documentation from relationship managers. Afterward, the team participated in the implementation and improvement of the AML/KYC remediation processes through updated procedures, checklists, KPIs definition and the creation of new frameworks based on the statistical analysis of the project results to ensure a more effective AML/KYC structure.

CUSTOMER GOAL

Our client’s main goals were :

  • Updating the KYC database in line with regulatory requirements.
  • Reviewing the existing information and documentation present in the original database and identification of gaps in the available data.
  • Collecting data from Relationship Managers to fill the gaps.
  • Assessing the customer’s client base risks for AML and CTF purposes.

Secondary goals evolved over the assignment period into the creation of new frameworks to ensure a more efficient AML/KYC structure and data collection methods.

CHALLENGES

The key challenges for the project were its large scope and length. Over a period of almost 2 years, hundreds of customer profiles around the globe were reviewed which required the collaboration of a large number of stakeholders.

The international scale of the project also turned out to be a regular challenge, as divergent local regulations had to be respected as accurately as possible without infringing on another, which was also the case for the different countries’ own habits in regards to customer privacy.

SOLUTION

In order to review all existing customer KYC information, the team had to split up the customer base and enter discussions with the different Relationship managers to pre-fill the Due Diligence documentation to the extent possible before asking the client to complete any unavailable information.

The experience gained during the collection of information and filling of documentation gaps allowed for the creation of new frameworks based on the statistical analysis of the project results. This ensured a more effective AML/KYC structure and the improvement of the existing risk-rating grid for the customer’s client base. The gathered experience also allowed the team to draft a list of ineffective points in the processes as well as shortcomings and gaps identified during the assignment with recommendations on how to mitigate them.

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